Practice Areas

Catfish Inspection Rule Effect on Importers to be Focus of USDA Meetings

Wednesday, February 24, 2016

Sandler, Travis & Rosenberg Trade Report

The Department of Agriculture’s Food Safety and Inspection Service has announced a series of meetings to provide information to importers on bringing Siluriformes fish (including catfish) and fish products into the United States. The meetings will be held March 3 in Newark, March 17 in Los Angeles and March 24 in Houston. If there is sufficient interest, meetings may also be held in Miami and Norfolk.

On Dec. 2, 2015, FSIS published a final rule to establish a mandatory inspection program for fish of the order Siluriformes and products derived from these fish. This rule will go into effect March 1, by which date foreign countries seeking to continue exporting these goods to the U.S. during an 18-month transitional period must submit documentation showing that they have laws or other legal measures in place that provide authority to regulate the growing and processing of fish for human food and to assure compliance with the Food and Drug Administration regulatory requirements in 21 CFR 123. Also by that date such foreign countries must submit lists of establishments that currently export and will continue to export such goods to the U.S.

Foreign countries seeking to continue to export these goods to the U.S. after the transitional period has expired are required to submit to FSIS, by Sept. 1, 2017, adequate documentation showing the equivalence of their Siluriformes inspection systems with that of the U.S. Those that meet this deadline will be permitted to continue exporting covered products to the U.S. while FSIS undertakes an evaluation as to equivalency.

The purpose of the upcoming meetings is to provide importers information on the final rule’s requirements, with a primary focus on the process for importing Siluriformes fish and fish products into the U.S. during the 18-month transitional period and on the date of full enforcement. Other topics will include labeling requirements, FSIS sampling and enforcement.